Ukraine

Anti-corruption compliance in Ukraine

Ukraine’s anti-corruption framework matters well beyond its borders. It affects who can bid on large public contracts, what reconstruction funding requires and how far the country gets on EU accession.

Compliance guidance, not legal advice.

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The Law on Prevention of Corruption and anti-corruption programs

The Law on Prevention of Corruption (No. 1700-VII of 14 October 2014) requires an approved anti-corruption program from state and municipal enterprises, and companies with more than 50 percent state or municipal ownership, that have more than 50 employees and gross revenue above UAH 70 million. It also applies to any legal entity taking part in a public procurement procedure where the purchase value is UAH 20 million or more (Article 62 of the Law on Prevention of Corruption). The program must be discussed with employees, kept accessible to them and built into employment contracts, and an authorized person must run it ^[Law] ^[NACP].

The National Agency on Corruption Prevention (NACP) does not approve companies’ programs ^[NACP]. It has issued a Standard Anti-Corruption Program (Order No. 794/21 of 10 December 2021) that covered entities are to use as the basis for their own.

The Law on Public Procurement makes this a bidding condition. Under Article 17(1)(10), a customer must reject a bid from a Ukrainian-registered legal entity that has no anti-corruption program or authorized person where the procurement value is UAH 20 million or more, including per lot. The requirement does not apply to non-resident bidders. Customers must also reject bids where, among other grounds, the entity is on the Register of corruption offenders or its authorized representative has been held liable for a corruption or corruption-related offense (Article 17(1)(2)–(3)) ^{[Procurement Law]}. During martial law, procurement runs under Cabinet Resolution No. 1178, which mirrors these exclusion grounds with self-declaration by bidders at the bid stage ^{[Resolution 1178]}; amendments to Article 17 take effect on 24 March 2027 ^{[Procurement Law]}.

Separately, Articles 96-3 to 96-11 of the Criminal Code allow criminal-law measures against legal entities, including a fine of twice the undue benefit, where an authorized person commits bribery and related offenses in the entity’s interest or the entity fails to prevent them. Since Law No. 4111-IX (December 2024), measures can be applied in foreign bribery cases without a conviction of an individual ^{[Criminal Code]}.

Enforcement: NABU, SAPO and the HACC

The National Anti-Corruption Bureau (NABU) investigates high-level corruption, including bribery, abuse of office and illicit enrichment involving senior officials and heads of major state-owned enterprises ^[NABU]. The Specialized Anti-Corruption Prosecutor’s Office (SAPO) supervises NABU’s investigations and prosecutes its cases, and the High Anti-Corruption Court has heard them since September 2019 ^[U4]. In July 2025 parliament passed a law placing NABU and SAPO under the Prosecutor General; after protests and pressure from EU partners, a law restoring their independence was signed on 31 July 2025 ^{[Kyiv Independent]}.

Reconstruction funding and EU accession

The EU’s Ukraine Facility provides up to €50 billion for 2024–2027 to support recovery, reconstruction and modernization. Payments are made quarterly when agreed conditions are met, including respect for the rule of law, and the Commission and Ukraine must protect EU financial interests by countering fraud, corruption and conflicts of interest ^{[Ukraine Facility]}. On 15 June 2026 the EU opened the “fundamentals” cluster of accession negotiations, covering the rule of law, public procurement and financial control ^{[EU Enlargement]}.

FCPA, UK Bribery Act and ISO 37001

A U.S.-linked company active in Ukraine can face Ukrainian law and the FCPA together. The U.S. Foreign Corrupt Practices Act (FCPA) applies to U.S. persons, issuers of U.S.-listed securities and certain foreign firms that act in furtherance of a corrupt payment within U.S. territory, and U.S.-listed issuers must also keep accurate books and adequate internal accounting controls ^[FCPA]. Since June 2025, DOJ enforcement guidelines prioritize conduct such as cartel-linked bribery, harm to identifiable U.S. companies and national-security-related corruption ^{[DOJ guidelines]}. Prosecutors assess compliance programs against the DOJ’s Evaluation of Corporate Compliance Programs, updated in September 2024 ^[ECCP].

Section 7 of the UK Bribery Act 2010 makes a commercial organization that carries on a business, or part of a business, in the UK guilty if a person associated with it bribes to win business for it, unless it had adequate procedures to prevent that ^{[UKBA s.7]}. ISO 37001 (second edition, 2025) sets requirements and guidance for an anti-bribery management system ^[ISO].

How AS3 helps

AS3 Compliance Consulting advises on FCPA, anti-corruption and compliance programs. For companies with operations in Ukraine that means program assessment and gap analysis, third-party due diligence and oversight, and policies, controls, training and monitoring. Engagements are delivered across Europe, the Middle East, Africa and Asia.

The Anti-Corruption Self-Assessment (FCPA, with ISO 37001 mapping) scores your program across 18 elements. It is available by paid license, and access is provided by code after approval. The buttons below only open a request form.

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Compliance guidance, not legal advice. For questions of Ukrainian law, consult qualified local counsel.

Sources

Last reviewed November 2026.

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